About

Welcome to PSR's Environmental Health Policy
Institute, where we ask questions -- then we ask the experts to
answer them. Join us as physicians, health professionals,
and environmental health experts share their ideas, inspiration, and
analysis about toxic chemicals and environmental health policy.

Advocating for Policy Change to Require Clinical Diagnostic Tools and Biomonitoring of Exposures to Pesticides

In 2010, the American Public Health
Association (APHA) passed a policy resolution urging the US Environmental
Protection Agency (EPA) to require pesticide manufacturers to develop methods
for detecting human exposure to their chemicals. The resolution highlights a growing
effort among clinicians, researchers, and advocates to better protect farmworkers
and other populations overexposed to pesticides. The policy statement, “Requiring
Clinical Diagnostic Tools and
Biomonitoring of Exposures to Pesticides,”is excerpted below.

The effort of preparing and obtaining
APHA endorsement for a policy resolution is an effective way to articulate an issue
that can be used in broader advocacy efforts. APHA members draft a statement for
review and endorsement either as an individual or as a section. It is then submitted
to the APHA Joint Policy Committee (JPC) and undergoes rigorous peer-review.
The authors and others are given an opportunity to respond to reviewer comments
and revise. Once accepted by the JPC, together with their section, the authors
seek endorsement from other sections and caucuses to garner support and educate
APHA members about the resolution. At the annual APHA meeting, all resolutions
are discussed at an open hearing of the Governing Council (comprised of the elected
members of all APHA sections and state-affiliates) and ultimately either passed
or rejected.

APHA and its state affiliates
represent over 50,000 health professionals and others who work to promote
health and prevent injury and disease. Public policy statements adopted through
this process provide the basis of the Association's stance on public health
issues. A policy statement endorsed by the largest public health organization
in the nation is a powerful tool in continuing efforts to promote an issue. We
are members of APHA’s Occupational Health and Safety Section and drafted Requiring
Clinical Diagnostic Tools and
Biomonitoring of Exposures to Pesticides. We continue to use this and other policy statements in efforts to
advocate for better protection of workers. The topic of biomonitoring will be
addressed by EPA during a day-long meeting in Washington, DC
on October 11, 2011. For more information on this meeting click here.

The EPA is responsible for the welfare of workers
exposed to pesticides in the agricultural workplace, farmworker families, and
the health of the public with respect to pesticides in food and the
environment.14–16 The EPA’s authority to oversee farmworker
protection from pesticide exposure can be found in its regulatory authority
under the Federal Insecticide Fungicide and Rodenticide Act of 1972 (FIFRA).14
FIFRA mandates that EPA, and not the Occupational Safety and Health
Administration (OSHA), promulgate the regulatory standards to protect workers
and their families from pesticide exposure.14,17 Consequently, EPA
and its designated state regulatory agencies oversee the worker protection
standard (WPS), the primary regulatory standard that mandates workplace
protection for hired agricultural laborers. The WPS involves pesticide safety training, notification of
pesticide applications, use of personal protective equipment, restricted entry intervals
after pesticide application, decontamination supplies, and emergency medical
assistance.16 It is notably weaker than similar regulatory
standards for occupations other than agriculture, and the WPS is poorly
enforced.18,19

Unlike OSHA,
which in multiple standards requires that employers conduct medical monitoring
of workers exposed to harmful substances,20 EPA has no requirements
for monitoring of workers exposed to pesticides. An essential component of the
information that EPA uses to make decisions about the removal or restriction of
use of a pesticide once on the market is information from surveillance systems.21
Several toxic pesticides have lost registration in the United States largely because of
the information available to EPA through surveillance of pesticide poisonings.
Examples include ethyl parathion and mevinphos.22 However, the
ability of clinicians to report exposures through pesticide illness
surveillance systems depends on their ability to diagnose pesticide poisonings.
With the introduction to the marketplace of new pest-specific chemicals,
diagnosis of human overexposure becomes even more difficult, because no human
data on the health effects of these chemicals exist.23 Cholinesterase
activity, a marker of overexposure to organophosphate and carbamate pesticides,
offers the only easily available confirmatory test for pesticide poisoning, and
this marker is nonspecific. Washington and California require
cholinesterase biomonitoring for pesticide applicators. These biomonitoring
programs have been of substantial value in reducing overexposure by removing
workers from ongoing exposure24,25 and identifying flaws in the
system of worker protection.25

APHA recommends that EPA require pesticide registrants, as a
requirement for registration, to develop and provide to the public—

A sensitive and specific
diagnostic test or biomonitoring tool to detect either chemical-specific levels
in humans, the human health effects caused by their exposures, or both

A sensitive diagnostic test or biomonitoring tool to detect their chemical or
its effects in human beings, the cost of which will be covered by the
registrant.

Comments

Alyssa Owens said ..

It is important to have unbiased opinion when testing industrial product. It is absurd to leave testing up to the manufacturers who stand to profit... Big business does not care that pesticides are harmful to our health and to the health of the environment. It is time for the manufacturers to have the burden of proof. The Precautionary Principle is imperative because most synthetic pesticides are toxic and in very small amounts and all of us are exposed to them unless we live in a bubble. http://naturallawns.blogspot.com

September 21, 2011

Walter Jones said ..

The Occupational Health and Safety Section of APHA, known for its 95 years of worker health and safety advocacy, believes that burden of developing standardized human exposure detection methods should be undertaken by pesticide manufacturers and not the public. For many of these international producers, this request is consistent with the European REACH requirements to provide hazard identification, risk assessment and risk abatement measures for their products.